Oscar Valencia v. the State of Texas

CourtCourt of Appeals of Texas
DecidedNovember 24, 2021
Docket09-21-00065-CR
StatusPublished

This text of Oscar Valencia v. the State of Texas (Oscar Valencia v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oscar Valencia v. the State of Texas, (Tex. Ct. App. 2021).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-21-00065-CR __________________

OSCAR VALENCIA, Appellant

V.

THE STATE OF TEXAS, Appellee

__________________________________________________________________

On Appeal from the 9th District Court Montgomery County, Texas Trial Cause No. 20-11-14108-CR __________________________________________________________________

MEMORANDUM OPINION

Appellant Oscar Valencia appeals the trial court’s denial of his pretrial habeas

corpus application requesting that his bail be reduced from $500,000 to $200,000.

We affirm.

1 Background

A grand jury indicted Valencia with the first-degree murder of Eliseo Garza.1

The indictment alleged that Valencia “intentionally or knowingly caused the death

of an individual, namely: Eliseo Garza, by shooting Eliseo Garza with a firearm[]”

on or about November 16, 2020. See Tex. Penal Code Ann. § 19.02(b)(1), (c).

According to Valencia, on November 17, 2020, Valencia’s bond was initially set at

$100,000 with no contact conditions for Valencia’s wife and children, and the

following day the trial court signed an order increasing Valencia’s bond to $500,000.

Valencia filed an Application for Writ of Habeas Corpus Seeking Bail

Reduction and argued the following:

[] Valencia’s confinement and restraint is illegal because the bond [amount] is excessive, oppressive[,] and beyond the financial means of [] Valencia, in violation of the Eighth and Fourteenth Amendments to the United States Constitution, Article I, §§ 11, 13, and 19 of the Texas Constitution, and Articles 1[.]07, 1.09, 11.24, and 17.15 of the Texas Code of Criminal Procedure, and various case law standing for the proposition that confining an individual based on his or her inability to pay a monetary value beyond their financial means without meaningful consideration of other possible alternatives, is inherently unconstitutional.

Valencia specifically argued that the amount of the bond is “an instrument of

oppression[,]” “far exceeds” the amount necessary to ensure his appearance at future

court proceedings and is “far higher than that normally required of similarly-situated

1 It is alleged that Eliseo Garza was having an affair with Valencia’s wife. 2 defendants.” According to Valencia, neither he nor his family can pay the $500,000

bond, and he has strong ties to the community and no criminal history. Valencia also

argued he is not a flight risk because he surrendered his passport to the District

Attorney, he has no significant ties to any other country, and he owns a house with

a mortgage in Houston.

On February 22, 2021, the trial court held a hearing on the writ via Zoom,

heard testimony from Valencia’s sister, took judicial notice of the court’s file, and

stated the following reason for denying the reduction of Valencia’s bond:

My biggest concern in this case was the very public nature and the fact that the circumstances of this offense endangered the public significantly. You know, it was an altercation in public in a very busy part of our area and a very heavily populated part of our area. And the nature of the offense and the multiple firearms that were found, as well as the pretty clear indication that this was -- or in the probable cause that this was a premeditated circumstance. I just do not believe it is in the -- that the safety and welfare of the community is protected by a bond lower than $500,000. So I’m going to leave the bond where it is.

On March 8, 2021, the trial court held a subsequent hearing via Zoom and explained

that the purpose of the March 8th hearing was to allow the parties to make a record

of evidence that had been presented during the earlier informal hearing. The trial

court again denied the application, and Valencia appealed.

3 Evidence at the Hearing

Testimony of Rosalva Colvin

At the first hearing, Rosalva Colvin, Appellant’s sister who lives in Illinois,

testified that Valencia has worked at McBride Plumbing for about eighteen years,

and he supervises thirty to forty employees and has managed about fifteen sites at a

time. According to Colvin, as far as she knew the job would still be available to

Valencia if he were able to make bail. Colvin testified that Valencia has family in

Houston and Chicago. Colvin testified that it would not be a problem that the judge

had ordered that if Valencia made bail he could not go to where his wife lives

because his family can secure an apartment in the Houston area where Valencia

could live.

Colvin testified that Valencia is a United States citizen, has lived in the same

house “pretty much the whole time[]” he has lived in Houston, has a mortgage on

the house that he has always paid, and has equity in the house. According to Colvin,

Valencia has three children: one about to graduate from high school, one that is

almost sixteen, and a twelve-year-old that has autism. Colvin testified that she has

observed Valencia to be a good father who really loves his children. Colvin testified

that in Valencia’s community, he coached his daughter’s Little League for about

three years, has attended church, and has multiple friends. Colvin testified that as far

as she knows, Valencia has never been arrested other than in this case.

4 At the second hearing, Colvin testified that Valencia had no income and no

savings at the time of the hearing. According to Colvin, the family tried to make the

$500,000 bond but they were not able to do so, and the bondsmen they talked to

required more assets than the family had. Colvin testified that the family could make

a $200,000 bond, however.

Testimony of Detective Benjamin Nichols

At the second hearing, Detective Benjamin Nichols with the Montgomery

County Sheriff’s Office, who identifies and documents gang members in the

Montgomery County jail, testified that in December 2020 he called Valencia after

Nichols learned that Valencia’s victim’s father was potentially a member of the

Mexican Mafia. Detective Nichols testified that he became aware that the victim in

this case was a member of the “Houstone gang,” and there were members of the

“Houstone gang” and the Mexican Mafia gang incarcerated in the Montgomery

County jail. Detective Nichols inquired as to whether Valencia felt he was in danger

of retaliation and needed protective custody. According to Detective Nichols,

Valencia had stated he did not need protective custody but would let jail personnel

know if anything changed. Detective Nichols testified that nothing about his

interaction with Valencia led him to believe that Valencia was a member of a

criminal street gang or that Valencia was in any sort of danger while incarcerated at

the Montgomery County jail.

5 Testimony of Detective Sergeant Joel Gordon

At the second hearing, Detective Sergeant Joel Gordon with the Shenandoah

Police Department testified that he was the primary case agent investigating the case

and arrived within minutes of the offense on November 16th. Detective Gordon

described the scene as “chaotic” and that there was a deceased individual that had

been shot and was on the ground in a grassy area just south of a throughway near

City Hall and a rehab hospital. He also observed a witness “screaming and crying[,]”

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